Privacy Policy

Last updated: 30 August 2026

1. Who we are

This website and the Steppe with Confidence programme are operated by Matthew Hale, trading as Steppe with Confidence as a sole trader.

Website: https://www.steppewithconfidence.com

For the purposes of UK data-protection law, Matthew Hale is the controller of the personal information described in this Privacy Policy.

Contact details

Name: Matthew Hale
Email: matt@steppewithconfidence.com
Postal address: 8 (2/1) Nicolson Square, Edinburgh, Scotland, EH8 9BH
Telephone: +44 7538 389213

Steppe with Confidence provides its services only to people aged 18 or over.

2. What personal data we collect

Depending on how you interact with us, we may collect the following types of personal information:

Your name, email address, telephone number and other contact details.
Information you provide when requesting a brochure or joining the newsletter.
Information you provide in an application form.
Information discussed during an application or enrolment call.
Optional information about accessibility needs or adjustments.
Student readiness assessments, course work, progress information and feedback.
Brief notes used to support students and monitor their progress.
Video and audio recordings of lessons and applicant calls.
Messages sent through email, Slack, WhatsApp, Instagram or other agreed communication channels.
Payment and transaction information.
Information about how you use our website and marketing emails.
Testimonials, feedback and comments where you have agreed to their use.
Technical information such as your IP address, browser, device, website activity and cookie choices.

We do not intentionally collect more personal information than is reasonably necessary to provide our services.

3. How we collect your information

We collect information directly from you when you:

Join our newsletter.
Request a course brochure.
Complete an application form.
Book or attend a call.
Enrol on or participate in a programme.
Attend a live lesson.
Complete a readiness assessment or course activity.
Contact us by email, Slack, WhatsApp, Instagram or another communication channel.
Make a payment.
Visit or interact with our website.
Provide feedback or agree to supply a testimonial.

We may also receive limited information from the service providers we use, including Google, Jotform, MailerLite, Calendly, Stripe, Slack, WhatsApp, Meta and OpenAI.

4. Why we use your information

We use personal information only when we have a lawful basis for doing so.

To respond to enquiries and provide requested information

We use your information to respond to questions and send requested brochures or other information.

Our lawful bases are taking steps at your request before entering into a contract and our legitimate interests in responding to enquiries.

To assess applications and arrange calls

We use application information to determine whether the programme is suitable for an applicant and to arrange or conduct applicant calls.

Our lawful bases are taking steps at your request before entering into a contract and our legitimate interests in operating an appropriate admissions process.

To provide the programme

We use student information to deliver lessons, provide course materials, monitor progress, give feedback and provide support.

Our lawful basis is performance of our contract with you.

To make accessibility adjustments

Where you choose to tell us about accessibility needs, the information may include health-related or other special-category personal data.

We process this information with your explicit consent and, where applicable, to meet legal obligations relating to equality and reasonable adjustments.

To record lessons and applicant calls

We use recordings to allow students to rewatch lessons, review progress, provide feedback, maintain appropriate records and administer the programme.

Our lawful bases are performance of our contract, taking steps before entering into a contract and our legitimate interests in providing and improving the programme.

To send marketing emails

We use your contact details to send newsletters, course information and other marketing where you have signed up or where another lawful basis permits us to do so.

Our lawful bases are consent and, where applicable, our legitimate interests in promoting our services to people who have expressed an interest in them.

To analyse email engagement

MailerLite may tell us whether emails have been opened, which links have been clicked and how individual subscribers interact with our emails.

We use this information to measure campaign performance, operate follow-up automations, segment subscribers and understand individual engagement.

We rely on consent where required for tracking technologies and our legitimate interests in analysing lawfully collected engagement and tailoring communications.

To process payments and keep financial records

We use transaction information to process payments, administer enrolment, prevent fraud and meet accounting and tax obligations.

Our lawful bases are performance of our contract and compliance with legal obligations.

To understand website use

We use analytics and basic website statistics to understand how visitors use the site and improve its content.

Where required, we rely on your consent. We may also rely on our legitimate interests for limited, privacy-conscious analysis that does not require consent.

To establish or defend legal claims

We may retain or use relevant information where necessary to establish, exercise or defend legal claims.

Our lawful bases are our legitimate interests and compliance with legal obligations.

5. Applications, applicant calls and accessibility information

Applications are currently collected using Jotform.

The application form may invite you to disclose accessibility needs. Providing this information is optional. You may instead choose to discuss accessibility requirements during an initial call.

Accessibility information may be contained in:

Your Jotform application.
A recording of an applicant call.
Brief student-support notes.

Because accessibility information may reveal health-related or other special-category personal data, we will ask for your explicit consent to record and use it for this purpose.

You may withdraw that consent, although doing so may limit our ability to provide a requested adjustment if we have no other suitable information.

Only calls with applicants are routinely recorded. If an applicant does not enrol, the recording is normally retained for three months. If the applicant enrols, the recording becomes part of the student record and is normally retained for 12 months after the programme ends.

Unsuccessful or withdrawn application forms are normally retained for six months after the application process ends. Application information for enrolled students is normally retained for 12 months after the programme ends.

6. Course delivery and lesson recordings

Enrolled students use an unlisted Google Site that requires Google sign-in. Course materials and pre-recorded videos may be stored in Google Drive.

Students are intended to retain access to the course site indefinitely while the site continues to exist. We must therefore retain the email address connected with course access for as long as that access is provided.

You may ask us to remove your access and delete the relevant access record, but this will mean that you can no longer use the course site.

Weekly live lessons are delivered using Google Meet. All live lessons are recorded.

Lesson recordings are used so that students can:

Rewatch lessons.
Review their progress.
Receive personalised feedback.

Group-lesson recordings may be accessed only by Matthew Hale and the members of the relevant cohort. They are not made available to later cohorts or used for marketing without separate permission.

Lesson recordings are normally kept for six months after the programme ends and are then deleted, unless a longer period is necessary for a legal claim or another compelling reason.

A lesson recording may contain a participant’s name, voice, image, messages and contributions to class discussions.

If you do not want your image to be recorded, please contact us before the lesson. We will discuss an individual adjustment, which may include attending with your camera switched off or another suitable arrangement.

7. Student assessments, progress information and notes

Readiness assessments and related results may be stored in Google Drive or Google Docs.

We may also create brief notes concerning:

Student progress.
Feedback and learning priorities.
Attendance and participation.
Accessibility adjustments.
Relevant student-support matters.

These records are used to deliver the programme, provide personalised feedback and monitor student progress.

Student assessments, progress records and accessibility or support notes are normally retained for 12 months after the programme ends.

8. Course communications

Slack

A Slack workspace may be used for course communication and student support.

Steppe with Confidence currently uses Slack’s free plan. On this plan, only the most recent 90 days of message history and files may be visible to workspace users. According to Slack’s current free-plan retention arrangements, data more than one year old is deleted.

Slack controls parts of this retention process under its own terms and policies.

Students may optionally contact Matthew Hale through a personal WhatsApp account for course-related support.

Because this is a personal account, students should avoid sending information that is not needed for their support. WhatsApp messages and media under our control are normally retained for 12 months after the programme ends.

You do not have to use WhatsApp. Another reasonable communication method can be agreed where appropriate.

9. Newsletters, brochures and email tracking

Our newsletter and optional brochure sign-up form is hosted by MailerLite.

The form will make clear that you are signing up to receive the Steppe with Confidence newsletter. You may also select an additional, unticked option if you would like to receive the course brochure.

MailerLite may be used to send:

The requested brochure.
A short follow-up email sequence.
Ongoing newsletters and marketing emails.

You can unsubscribe from marketing emails at any time by using the unsubscribe link in an email or by contacting matt@steppewithconfidence.com.

You have an absolute right to object to the use of your personal information for direct marketing.

MailerLite may collect information about email opens, link clicks and subscriber activity. We currently use this information to:

Review aggregate campaign performance.
Trigger follow-up automations.
Segment subscribers.
Review an individual subscriber’s activity where relevant.

Email tracking can involve tracking technologies and may be subject to additional consent requirements under UK privacy and electronic-communications law. Our tracking and consent arrangements should be kept under review to ensure that they comply with these requirements.

We normally keep newsletter contact details and subscriber profiles while you remain subscribed.

After you unsubscribe, we aim to delete or anonymise unnecessary profile and engagement information within 12 months. We may retain a minimal suppression record so that we can respect your request not to receive further marketing.

10. Website analytics, cookies and embedded content

Our website is hosted using Google Sites.

Google Sites displays Google’s built-in cookie-consent banner, which allows visitors to accept or reject cookies. Where the banner operates as described by Google, rejecting cookies prevents non-essential cookies, including Google Analytics cookies, from being used.

We use:

Google Analytics.
Google Sites’ basic website statistics.
MailerLite email and subscriber tracking.

Google Analytics may collect information including your IP address, device, browser, approximate location and interaction with the website.

Where Google Analytics provides a configurable user-level and event-level retention setting, we intend to retain this data for no longer than 14 months. Aggregated reports that no longer identify individual users may be kept for longer.

You can control cookies through the website banner and through your browser settings. Disabling cookies may affect how some parts of the website work.

Pages on this site may include embedded content, such as videos, images or articles. Embedded content behaves in substantially the same way as if you had visited the third-party website directly.

Those websites may collect information about you, use cookies, embed additional tracking and monitor your interaction with their content, particularly if you have an account with that provider and are signed in.

11. Social media

Steppe with Confidence uses Instagram direct messages to communicate with prospective students and other contacts.

Instagram conversations concerning a prospect are normally retained for 12 months after the last meaningful contact, unless the conversation becomes part of an application, student record, complaint or legal matter.

Meta advertising is not currently used. If Meta advertising or associated tracking technologies are introduced in the future, this Privacy Policy and the website’s cookie information will be updated before or when those tools begin processing personal information.

12. Payments

Payments are currently accepted through Stripe by card.

Stripe processes payment-card details under its own privacy terms. Steppe with Confidence does not normally receive or store your complete card number.

A parent or another person may pay on a student’s behalf. In that situation, we may process the payer’s name, contact details, transaction information and relationship to the student where necessary to administer the payment.

Payment and financial records may be retained for the period required by UK tax and accounting law. For a UK sole trader, this will generally be at least five years after the 31 January filing deadline for the relevant tax year.

13. Optional Custom GPT activities

Students may be offered optional homework activities using Custom GPTs within ChatGPT.

The Custom GPTs are manually configured by Matthew Hale and operate only within ChatGPT. They do not use external actions or connected third-party applications.

Use of the Custom GPTs is optional. A reasonable alternative activity can be provided if you do not wish to use ChatGPT.

When you use a Custom GPT:

OpenAI processes the information you submit under its own terms and privacy policy.
The GPT builder does not receive access to your individual ChatGPT conversations.
Whether OpenAI uses conversations to improve its models may depend on your ChatGPT account type and Data Controls settings.
You should avoid entering unnecessary sensitive or confidential information.

OpenAI’s European privacy policy is available at:

https://openai.com/en-GB/policies/eu-privacy-policy/

14. Historical readiness-quiz responses

The Year Abroad Readiness Quiz is being discontinued.

Historical responses previously collected using Google Forms will be retained temporarily for review. They will be deleted or properly anonymised within one month, by 30 September 2026.

Once that process has been completed, this transitional section can be removed from the Privacy Policy.

15. Service providers and other recipients

We use third-party service providers to operate the website, communicate with students, deliver the programme and process payments.

Google

Purposes: Website and course-site hosting, Google sign-in, Google Meet lessons and recordings, Google Drive and Docs storage, forms, analytics and basic website statistics.

Jotform

Purpose: Collecting programme applications.

MailerLite

Purposes: Newsletter and brochure forms, marketing emails, automations and email-engagement information.

Calendly

Purpose: Scheduling calls.

Stripe

Purposes: Processing card payments and preventing payment fraud.

Slack

Purpose: Course communication and student support.

Purpose: Optional student support and communication.

Meta and Instagram

Purpose: Social-media communication through Instagram direct messages.

OpenAI

Purpose: Optional Custom GPT course activities.

These providers may process information as our processors, as independent controllers or in a combination of those roles, depending on the service and circumstances.

We may also disclose information where required by law, to professional advisers, or where reasonably necessary to establish, exercise or defend legal claims.

Steppe with Confidence does not sell personal information.

16. International transfers

Some of our service providers may store or process personal information outside the United Kingdom.

Where personal information is transferred internationally, we expect the relevant provider to use a lawful transfer mechanism. Depending on the destination and provider, this may include:

UK adequacy regulations.
The UK International Data Transfer Agreement.
The UK Addendum to the European Commission’s standard contractual clauses.
Another legally permitted safeguard.

You can contact us if you would like further information about the safeguards relevant to a particular provider.

17. How long we retain information

We keep personal information only for as long as reasonably necessary for the purpose for which it was collected, including legal, tax, accounting and reporting requirements.

Our intended retention periods are:

Unsuccessful or withdrawn applications

Retained for six months after the application process ends.

Recorded applicant calls where the person does not enrol

Retained for three months after the decision not to enrol or withdrawal.

Application forms and applicant-call recordings for enrolled students

Retained for 12 months after the programme ends.

Lesson recordings

Retained for six months after the programme ends.

Student progress, accessibility and support notes

Retained for 12 months after the programme ends.

Readiness assessments and related results

Retained for 12 months after the programme ends.

WhatsApp student conversations

Retained for 12 months after the programme ends.

Slack messages and files

Visibility is generally limited to the most recent 90 days under the current free plan. Slack states that free-workspace data more than one year old is deleted.

Instagram prospect conversations

Retained for 12 months after the last meaningful contact.

General enquiries, sales correspondence and Calendly records

Retained for 12 months after the last meaningful contact, unless they become part of an applicant or student record.

Newsletter contact details and subscriber profiles

Retained while you remain subscribed. Unnecessary profile and engagement information is deleted or anonymised within 12 months after unsubscribing, except for a minimal suppression record.

Google Analytics user-level and event-level data

Retained for up to 14 months. Aggregated, non-identifying reports may be retained for longer.

Course-site access email address

Retained while continued course-site access is provided or until you ask us to remove access.

Payment and tax records

Retained for the legally required accounting and tax period, generally at least five years after the relevant 31 January tax-return deadline.

Historical readiness-quiz responses

Deleted or properly anonymised by 30 September 2026.

We may retain particular records for longer if they are relevant to a complaint, dispute, safeguarding matter, legal claim or legal obligation.

18. Your data-protection rights

Depending on the circumstances, you may have the right to:

Ask for access to the personal information we hold about you.
Ask us to correct inaccurate or incomplete information.
Ask us to delete your personal information.
Ask us to restrict how we use your information.
Object to processing based on legitimate interests.
Object at any time to direct marketing.
Ask to receive certain information in a portable format.
Withdraw consent at any time where we rely on consent.
Complain to the Information Commissioner’s Office.

Withdrawing consent does not affect the lawfulness of processing carried out before the withdrawal.

Some rights are subject to legal exceptions. For example, we may need to keep information to meet tax, accounting, legal or security obligations.

To exercise a right, contact:

matt@steppewithconfidence.com

We may need to confirm your identity before responding. We normally respond within one month, although the law permits additional time for particularly complex or numerous requests.

19. Complaints

If you have concerns about how we use your information, please contact us first so that we have an opportunity to address them.

You also have the right to complain to the Information Commissioner’s Office, the UK supervisory authority for data protection.

Website: https://ico.org.uk/make-a-complaint/
Telephone: 0303 123 1113

20. Security and confidentiality

We take reasonable organisational and technical measures to protect personal information against accidental loss, unauthorised access, misuse, alteration or disclosure.

Access to student records and lesson recordings is restricted to people who reasonably need it for programme delivery or administration.

Members of a cohort may see or hear other participants in group lessons and may have access to recordings from their own cohort. Students are asked not to download, copy, publish or share another participant’s image, voice, messages or contributions without permission.

No online service or storage system can be guaranteed to be completely secure.

21. Automated decision-making

We do not use solely automated decision-making that produces legal or similarly significant effects concerning applicants or students.

Email automations and subscriber segmentation may be used to determine which marketing messages are sent, but they do not make decisions about admission to the programme or a student’s legal rights.

22. Testimonials, feedback and anonymised insights

We may use genuinely anonymised information about common learning challenges, goals or experiences to improve our programme or marketing. Anonymised information will not identify you and will not be linked back to your personal record.

We will obtain separate, explicit permission before using:

Your name.
Your photograph or image.
A lesson or call recording.
An attributable quotation.
A recognisable personal story.
Any other material that identifies you as a testimonial or case study.

Refusing or withdrawing testimonial permission will not affect your access to the programme.

Withdrawal cannot always remove material that has already been printed or lawfully published, but we will stop new uses where reasonably possible.

23. A note on generative artificial intelligence

In the interests of transparency, the Steppe with Confidence company logo was created with assistance from generative artificial intelligence.

Elements of the website copy have been shaped through limited AI feedback. The copy was originally written and edited by Matthew Hale with assistance from Rachael Roberts of Earn Learn Thrive Ltd.:

https://earnlearnthriveinelt.com

The programme also offers optional Custom GPT activities through ChatGPT. These GPTs have been manually configured by Matthew Hale.

Steppe with Confidence encourages students to develop a healthy and informed relationship with artificial intelligence while emphasising that they should not become reliant on it.

Students, prospective students or other interested parties may contact us using the details at the beginning of this policy if they would like to discuss our use of artificial intelligence.

24. Changes to this Privacy Policy

We may update this Privacy Policy when our services, providers or legal obligations change.

The latest version will be published on this website with a revised “last updated” date. If a change materially affects how we use existing personal information, we will take reasonable steps to bring it to the attention of affected individuals.